Paragraph 6

After section 835G insert—

“Brokers

835H

(1)

This section applies if a non-UK resident carries on (alone or in partnership) a business through a broker in the United Kingdom.

(2)

The broker is not the UK representative of the non-UK resident in relation to an amount within section 835E(2) if—

(a)

the amount is transaction income in relation to a transaction carried out through the broker in the United Kingdom on behalf of the non-UK resident, and

(b)

the independent broker conditions are met in relation to the transaction (see section 835L).

(3)

In subsection (2) “transaction income”, in relation to a transaction carried out through a broker in the United Kingdom on behalf of a non-UK resident, has the same meaning as in Chapter 1 (see section 814(5)).”